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   500
                                            Cummings Center

Beverly,
MA 01915

1.978.619.1300

www.atni.com

July 29, 2024

VIA EDGAR

Securities and Exchange Commission

Division of Corporation Finance

100 F. Street, N.E.

Washington, D.C. 20549

 Re: ATN International, Inc.

Form 10-K for the fiscal year ended December 31, 2023

File No. 001-12593

To Whom it May Concern:

On behalf of ATN International, Inc. (the
“Company”), we submit this letter in response to comments from the staff (the “Staff”) of the United States Securities
and Exchange Commission (the “Commission”) contained in its letter dated July 17, 2024, relating to the above referenced
Form 10-K for the fiscal year ended December 31, 2023 (the “Form 10-K”).

For the Staff’s convenience, the Staff’s
comments have been stated below in their entirety in bold, followed by the corresponding responses from the Company. Capitalized terms
used but not defined in this letter have the meanings ascribed to such terms in the Form 10-K.

Form 10-K for the fiscal year ended December 31, 2023

Item 9A. Controls and Procedures, page 59.

 1. You disclose that management assessed the effectiveness of your internal
control over financial reporting as of December 31, 2023; however, you do not to include a statement as to whether
or not internal control over financial reporting is effective. Please amend your filing to include this disclosure. Refer to Item 308(a)(3) of
Regulation S-K.

Response:
The Company respectfully acknowledges the Staff’s comment and has amended the Form 10-K to clarify in Item 9A
that management concluded that its internal control over financial reporting was effective at the end of the fiscal year. The Company
inadvertently omitted from the Form 10-K the following statement:

“Based on its assessment, management concluded
that, as of December 31, 2023, our internal control over financial reporting was effective based on those criteria.”

Language included in Item 9A of the Form 10-K
made clear that the effectiveness of the Company’s internal controls over financial reporting was assessed as of December 31,
2023, using the criteria set forth by the Internal Control—Integrated Framework (2013) issued by the Committee of Sponsoring
Organizations of the Treadway Commission (“COSO”). Additionally, the Form 10-K certifications of the Company’s
principal executive officer (Exhibit 31.1) and its principal financial officer (Exhibit 31.2) each state that they have “designed
such internal control over financial reporting, or caused such internal control over financial reporting to be designed under our supervision,
to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external
purposes in accordance with generally accepted accounting principles.”

Without minimizing the appropriateness of promptly
amending the Form 10-K to add the omitted sentence, the Company believes that, based upon the foregoing disclosures included in the
Form 10-K, reasonable users of the Form 10-K would have believed that the required assessment had been completed and that the
internal control was deemed to be effective as of the end of the fiscal year.

* * * *

If you have any questions or comments regarding
these responses or require any additional information, please do not hesitate to contact Mary Mabey, the Company’s General Counsel,
at mmabey@atni.com.

    Regards,

    ATN INTERNATIONAL, INC.

    By:
     /s/ Carlos R. Doglioli

    Name:
    Carlos R. Doglioli

    Title:
    Chief Financial Officer